Title Iii Of The Patriot Act: A Review Of Effectiveness In Combating .
TITLE III OF THE PATRIOT ACT:A REVIEW OF EFFECTIVENESS IN COMBATINGTERRORIST FINANCINGbyR. Benson ErwinA thesis submitted to Johns Hopkins University in conformity with the requirements forthe degree of Master of Arts in GovernmentBaltimore, MarylandMay, 2015 2015 R. Benson ErwinAll Rights Reserved
Abstract:The September 11, 2001 terrorist attacks marked a paradigm shift in United Statesnational security policy from one based on deterrence of hegemonic rivals to one basedon counterterrorism. Initial counterterrorism efforts focused squarely on the mainperpetrators of the attack, Al Qaeda, but in his war declaration address to a joint sessionof Congress on September 20, 2011, President Bush outlined the forthcoming shift- “Ourwar on terror begins with al Qaeda, but it does not end there. It will not end until everyterrorist group of global reach has been found, stopped and defeated.”1Since President Bush’s declaration of a global war on terror in September 2001,Al Qaeda, due to concentrated efforts focused on proactive intelligence gathering andmilitary interdiction, has been degraded. Due to this fractured network, Al Qaeda hasdevolved into loosely connected sub-sects, affiliate organizations, and non-affiliatesympathizers. Given this transformation, and the terrorist networks that persist, AlQaeda, its affiliates, and the terrorist groups that continue to target the United Statesremain of primary national security concern.One of the major focuses, manifested in the passage of the Uniting andStrengthening America by Providing Appropriate Tools Required to Intercept andObstruct Terrorism Act of 2001 (Patriot Act), is an effort to combat terrorist financing.Given the unconventional means of a terrorist attack, coupled with the freedom withwhich operational funds can move from country to country, terrorist financing poses aparticularly nuanced threat. Nearly fifteen years have passed since the 9/11 attacks and itis critical to United States national security to reflect on the country’s counterterrorismii
efforts, learn from successes and failures, and make appropriate changes to ensure thatthe United States continues to adequately address the ever-changing nature of terroristthreats. Is the country safer? Have we achieved the goal of effectively combatingterrorist financing?By looking at the effect of Title III of the Patriot Act domestically,internationally, and on informal financial networks, we can assess the successes andfailures of the financial provisions of the Patriot Act.Advisors: Dr. Kathy Wagner Hill; Dr. Dorothea WolfsonReaders: Mark Stout; James Van de Velde1The Office of the President of the United States, “Address to a Joint Session of Congress and theAmerican people,” leases/2001/09/20010920-8.htmliii
PrefaceAcknowledgmentsThe writer would like to thank his grammatically inclined friend for her thanklessedits, and the Johns Hopkins University professors, especially his advisors who fieldedquestions and concerns during off-peak business hours, for their patience and guidance.iv
Table of ContentsAbstract .ii-iiiPreface ivTable of Contents .vIntroduction .1-7Section I: Domestic Policies .8-24Section II: International Partners . .25-40Section III: Informal Networks .41-55Key Findings and Conclusion .56-61Bibliography. . .62-70Curriculum Vitae .71v
Introduction:National Security. When evaluating the term in its most elemental sense, manywould identify its meaning as the concept of global powers posturing to protectthemselves from equally powerful competitor countries. The meaning is justifiable whenlooking through a historical scope. However, with global powers in a relative peace,United States national security policy in the modern era, prompted by the September 11,2001 attacks, has broken from tradition to address the threats of the day.2,977.2 This number, overwhelming in its significance, has defined modernUnited States national security policy. On September 11, 2001, 2,977 men, women, andchildren, were killed in a coordinated terrorist attack on the United States. Since thattime, United States national security policy has continually changed to address theasymmetric threat posed by terrorism. Counterterrorism strategy has come to mean anabsolute and all-encompassing effort from the public and private sector alike. Since 9/11the United States has worked on a multi-agency and global level to defend against thethreat posed by non-state actors who blend into an increasingly ambiguous globalnetwork. Of these efforts, one of the major focuses has been tracking and defeatingterrorist financing networks.As with any enterprise, the acquisition and distribution of capital is paramount tooperational success. In response to the 9/11 attacks, the United States governmentestablished tough financial restrictions in efforts to disrupt and dismantle terrorist fundingstreams. The most significant public policy outcome of the 9/11 attacks is the Unitingand Strengthening America by Providing Appropriate Tools Required to successfully1
Intercept and Obstruct Terrorism Act of 2001, commonly referred to as the Patriot Act(Public Law 107-56). Of the laws 10 sections, Title III of the Patriot Act focuses on theestablishment of enhanced financial provisions. The financial provisions in Title IIImandate increased due diligence in tracking, maintaining, and investigating financialtransactions. The aim of Title III of the Patriot Act is to uncover terrorist funding streamsand disseminate that information to the appropriate law enforcement personnel to takeaction. In answering the question of whether or not Title III has been effective incombating terrorist financing, this paper will examine the law’s implementation andmeasure the law’s success through a review of terrorist financing enforcement actionstaken as a result of the Title III provisions.In the fight to dismantle terrorist financing networks, it is critical to devoteadequate resources to programs and agencies that effectively uncover these networks.Section I of this paper will look inward at the effect of Title III of the Patriot Act ondomestic policies. Section I of this paper will test the Patriot Acts effectiveness through areview of Suspicious Activity (SAR) and Currency Transaction (CTR) Reports filed byfinancial institutions since 9/11, and the amount of terrorist related enforcement actionsthat have resulted due to the added reporting. While the Patriot Act was a major overhaulaffecting operations on multiple levels, Section I will focus directly on the financialprovisions within Title III of the act that directly pertain to domestic policies. It bearsmentioning other institutional moving parts associated with tracking terrorist financingfrom a domestic standpoint. For the purpose of Section I, the Patriot Act will be ofprimary focus but given the paralleling objectives, sometimes different strategies and2CNN Library, “September 11th Fast Facts,” last modified March 27, -anniversary-fast-facts/.2
policies brush up against one another in order to achieve a common goal. The BankSecrecy Act of 1970 established reporting of records of primary concern through theCurrency and Foreign Transactions Reporting Act (CFTRA).3 Through the CFTRA,reporting of transactions with a financial institution greater than 10,000 is required, inaddition to suspicious activity. The Suppression of the Financing of TerrorismConvention Implementation Act, regardless of territory, makes it a crime for UnitedStates citizens, or people acting within United States territories to financially supportterrorist activity.4 The Intelligence Reform and Terrorism Prevention Act of 2004 seeksto regulate certain transactions between financial institutions operating internationallythrough the United States Treasury Department.5 Under Executive Order 13224, theTreasury Secretary, in times of national emergencies, is tasked with using all resourcesavailable under the International Emergency Economic Powers Act to freeze assetsassociated with terrorism.6 The Treasury Department’s Terrorist Financing TrackingProgram (TFTP) is the unit within the Treasury that enforces these actions.While these enhancements add value to the anti-terrorist financing apparatus, theimpact and scope of the Patriot Act is pronounced. The Patriot Act is the countriesforemost roadmap for contemporary national security strategy, and its global impact is arelevant metric to consider. Section II of this paper will focus on the international impact3Murphy, Maureen M., and Elsea, Jennifer K., “CRS Report for Congress: Treasury’s Terrorist FinanceProgram’s Access to information Held by the Society for Worldwide Interbank FinancialTelecommunication,” Congressional Research Service (2006): 4.4Murphy, Maureen M., and Elsea, Jennifer K., “CRS Report for Congress: Treasury’s Terrorist FinanceProgram’s Access to information Held by the Society for Worldwide Interbank FinancialTelecommunication,” Congressional Research Service (2006): 4.5Murphy, Maureen M., and Elsea, Jennifer K., “CRS Report for Congress: Treasury’s Terrorist FinanceProgram’s Access to information Held by the Society for Worldwide Interbank FinancialTelecommunication,” Congressional Research Service (2006): 5.3
of Title III of the Patriot Act. Specifically, Title III of the Patriot Act squarely addressesissues posed by international money laundering with a focus on anti-terrorist financing.Al Qaeda is a multinational organization operating in an estimated 100 countries.7Al Qaeda’s influence, demonstrated through their former affiliate and current violentoffspring, the Islamic State of Iraq and Syria (ISIS), is proof positive in Al Qaeda’scontinued presence on the global violent extremist stage since the 9/11 attacks. As theterrorist threat to national security evolves, so should efforts to address the threat. AlQaeda’s methods for generating capital are diverse and span across the global divide withcommand and control efforts located outside of the continental United States. The natureof the 9/11 attacks, financed through Pakistan, masterminded in Afghanistan with actorsprimarily from Saudi Arabia that were residing in Germany, and ultimately executed inthe United States, had overt global roots.This paper will specifically address the foreign anti-terrorist financing componentof the Patriot Act. By looking at the contemporary means by which terrorists generateincome, the international safeguards implemented after 9/11 to address the threat, and thePatriot Act’s particular role in influencing those international safeguards, Section II willdraw a conclusion on the Patriot Act’s international influence and subsequent impact oncombating terrorist financing.While Section I addresses the domestic approach in the Patriot Act to createtransparency within formal financial institutions to combat terrorist financing, Section IIIwill discuss the steps taken to enforce informal networks. A major concern then and a6Murphy, Maureen M., and Elsea, Jennifer K., “CRS Report for Congress: Treasury’s Terrorist FinanceProgram’s Access to information Held by the Society for Worldwide Interbank FinancialTelecommunication,” Congressional Research Service (2006): 2.4
major concern now with respect to countering terrorist financing is the issue ofalternative remittance systems, otherwise known as informal value transfer systems(IVTS), or as referred to in the Middle East, hawala. This method of currencytransmission is a multi billion-dollar business and a common global practice, much of itlegitimate, especially in countries with an underdeveloped financial infrastructure that isvulnerable to terrorist manipulation. In the most basic of senses, IVTS logistics areaccomplished in one of two ways. IVTS is accomplished either through undergroundphysical transfers of currency, otherwise known as smuggling, or through networksoperating outside of legitimate financial institutions conducting word of mouth valuetransfers. In this case, there is no physical transfer of currency, and these unregulatedmarkets operate based on the terms agreed upon by the involved parties.Section III will look into the structural and cultural mechanisms that drive thisunderground network and their possible link to facilitating terrorist related activities.What kind of threat do these networks pose to the United States? How frequent are thesenetworks used to finance terrorism?After the September 11, 2001 attacks, a major focus was in the form oftransparency. Policy makers sought to find a way to better regulate this informalnetwork. After assessing the connection of this network to terrorist financing andwhether it is strong or weak, the paper will address the counter terrorist financing effortsincluded in the Patriot Act, and whether the provisions have effectively addressed theseconcerns. It bears mentioning that statistics do not paint an absolute picture due to thefact that much of these networks operate outside of any metric weighing system. By7“Council on Foreign Relations Al Qaeda Backgrounder,” last updated June 6, d-networks/al-qaeda-k-al-qaida-al-qaida/p9126#p35
looking at current trends we can address the effectiveness of the regulations, determinebest practices, and build on any missteps.Approximately fourteen years after 9/11, the inspirational leader of Al Qaeda, andthe man responsible for the 9/11 attacks, Usama bin Laden, is dead. Due to a persistentoffensive, Al Qaeda has since fragmented and diminished in size and operational scope.From an inspirational standpoint, the current leader of Al’Qaeda, Ayman al-Zahwahiri,does not command the cult-like loyalty Bin Laden once did.8 But despite the significantstrides taken to degrade the terrorist organization, the threat remains. As a result of thedisruption and dismantlement of Al Qaeda, the organization has become decentralized.The organizational structure of Al Qaeda represents more of a stovepipe network ofloosely affiliated terrorist cells that span across the Middle East, North Africa, and Asia.This structure will almost certainly impact Al Qaeda’s efforts moving forward.9 Theevolution of the terrorist threat exemplified by the rise of ISIS is a stark reminder that thethreat is ever-evolving. Not to mention the disturbing trend of homegrown terroristsympathizers, who have become increasingly emboldened and inspired. Both of thesepose a direct threat to domestic security. These terrorist networks rely on the chaos andinstability of volatile countries as an operational safe haven. The instability in the MiddleEast, most specifically in Syria, Iraq and Yemen, coupled with the trend in theunorganized terrorist structure signifies an evolution of the threat, and furtherdemonstrates an adaptability to adapt and thrive. As the threat continues to evolve, theconstant that perpetually remains is funding. As the 9/11 attacks have shown us, our8Senate Select Committee on Intelligence, “James R. Clapper Unclassified Statement for the Record on theWorldwide Threat Assessment of the US Intelligence Community,” the Senate Select Committee onIntelligence, January 31, 2012: 3.6
country was exposed to a non-state actor bent on overthrowing the US government.Paying close attention to the utility of the resources in place to counter the threat is anessential exercise.As the former deputy chief of the Counterterrorist Center within the CIA, PaulPillar states that “during periods of high interest in terrorism, there is a push to do moreof everything - more sanctions, more stringent requirements, heavier criminal penalties,wider application of existing rules - to satisfy a general desire to do more to fightterrorism, even if some of the measures adopted might not be well designed to reduceterrorism.”10 A review of the financial provisions of the Patriot Act will yield resultswith respect to this very notion.9Office of the President of the United States of America, “National Strategy for Counterterrorism,” June2011: 12.10Pillar, Paul, “Terrorism and U.S. Foreign Policy,” (Washington, DC: The Brookings Institute, 2003):205.7
Section I: Public-Private PartnershipsNature of the Threat:In order to track the threat it’s important to understand the threat. Like anyenterprise, raising capital provides material support and the means to survive and operate.This is no different for terrorist organizations. In order to raise money, terrorists seekfunding through various outlets. Al Qaeda solicits funds through donors who relate withtheir cause, whether it is through a charity or legitimate business. In addition, funding ispursued through criminal endeavors such as kidnapping for ransom; drug trafficking,extortion, credit card fraud, counterfeiting, and smuggling.11 Once requisite fundingstreams are established, the next step in the process is effectively distributing the funds topay for terrorist activity. With respect to circulating funds, terrorists have used wiretransfers, debit cards, or cash couriers, in addition to commodities and falsifyingdocuments in order to move funds discreetly.12 Another trend popular in the Middle Eastis an informal banking system otherwise known as “hawala”. These word of mouth, andessentially paperless transactions are based on familial and tribal connections, and pose aparticularly difficult problem, a nuanced and ambiguous form of operations part andparcel to terrorist activity.13 The flexibility, creativity, and adaptability of terrorists areevidenced through the different attacks and attempted attacks. Whether it be throughhijacking a plane, setting off bombs, or mailing bombs, it is clear that the end result ofdestruction is the guiding force, no matter what. Such seems to be the case as evidenced11The Office of the President of the United States of America, “National Strategy for CombatingTerrorism,” September 2006:12.12Financial Crimes Enforcement Network, “Annual Report,” 2005: 55.8
by the diverse fundraising efforts. As long as there is money coming in, the means inwhich it comes in does not seem to matter. An ever-evolving and dynamic threat,financing strategies can change from one day to the next. The 9/11 attacks spurred actionand the creation of contemporary policies to breakdown terrorist funding networks.Financing 9/11:As the 9/11 commission revealed, the financing of the 9/11 terrorist attacks for allintents and purposes went undetected. Before 9/11 much of the government’s efforts tocombat money laundering were focused on drug trafficking and large financial fraudincidents.14 For that reason, the 9/11 organizers were able to blend into the globalfinancial system without raising any concerns. The 9/11 attacks acted as a catalyst onmany different levels as the country was quickly exposed to a new threat. Al Qaeda wassuccessful in funding their objectives in secrecy within the global financial network.The funding of the 9/11 attacks stemmed from donors and fundraisers in theMiddle East, particularly Saudi Arabia.15 Al Qaeda relied on charitable organizations anddonations (zakat), a religious requirement, in order to finance their operation. Charitiesnot only provided a funding stream but also provided cover with charitable organizationsoperating as a front under the humanitarian umbrella.16 All funding stemmed fromforeign organizations; no domestic groups were tied to the attacks.13Financial Crimes Enforcement Network, “Annual Report,” 2005: 55.The National Commission on Terrorist Attacks Upon the United States, “the 9/11 Commission Report,”October 17, 2004: 171.15The National Commission on Terrorist Attacks Upon the United States, “the 9/11 Commission Report,”October 17, 2004: 171.16The National Commission on Terrorist Attacks Upon the United States, “the 9/11 Commission Report”,October 17, 2004: 171.149
After the money had been raised, the operational financing was set in motion. Inorder to finance the attack, terrorists moved money between U.S. and foreign accountsprimarily through wire transfers, deposits of cash or traveler’s cheques, and debit andcredit cards linked to foreign accounts.17 Of the 400,000-500,000 used for the attack,approximately 300,000 moved freely, and legally, throughout the hijacker’s establishedU.S. bank accounts.18 The unassuming nature in which this money was used enabled the9/11 attackers to blend into the global network as money was spent on cost of livingexpenses to include flight school training, travel, rent, food, and various other innocuousexpenditures.19 As a result of the oversight infrastructure in place, the governmentresponse was reactive, and thus ill prepared to flag the activity as suspicious.Additionally, the small amount of money it took to commit such an attack coupled withthe ease in which that money moved in and out of financial institutions posed animmediate concern and spurred quick executive action in the wake of the attacks.Government Response:The immediate response following the 9/11 attacks was robust. The governmentacted quickly to freeze questionable assets and terrorist funding streams. In response tothe attacks, President Bush issued Executive Order 13224 on September 23, 2001. Thismove enabled the Treasury Department to use necessary measures to track downfinanciers of terrorism. Within the Treasury, the Terrorist Financing Tracking Program17The National Commission on Terrorist Attacks Upon the United States, “Terrorist Financing StaffMonograph”, August 21, 2004: 6.18The National Commission on Terrorist Attacks Upon the United States, “Terrorist Financing StaffMonograph,” August 21, 2004: 6.19The National Commission on Terrorist Attacks Upon the United States, “the 9/11 Commission Report,”October 17, 2004: 170.10
was established to lead the fight in tracking terrorist financing and breaking up thefinancial networks that funded such activity. This order launched a multi-lateralresponse, pulling from both foreign and domestic resources to effectively track,dismantle, and name terrorists and organizations. Under this directive 200 millionworth of assets was seized or frozen.20 As predicted, the money led to names andorganizations that directly or indirectly financed terrorist activity. This critical paper trailwas the starting point in creating a black list of individuals and organizations involved interrorist financing. The individuals and organizations listed faced asset forfeiture andblockage, a tool utilized to freeze assets in the immediate months after 9/11. Inresponding to the global threat, the United States along with international supportmotivated quickly to track the money. Piggybacking on the success of Executive Order13224 was the Patriot Act, which sought to further the reach of the government intracking down and drying up terrorist financing.Patriot Act Financial Provisions:The Patriot Act was passed with little opposition on October 26, 2001. Alegislative phenomena with respect to the immediacy in which it was passed, the PatriotAct was the major legislative action taken in response to the 9/11 attacks. Title III of thePatriot Act, The International Money laundering Abatement and Anti-Terrorist FinancingAct of 2001, was the major financial overhaul within the act. These measures establishedseveral amendments to the Bank Secrecy Act, in addition to new rules to enhance theTreasury Department’s capabilities to track illicit funds. The major domestic objective of20House Subcommittee on Oversight and Investigations, “Patriot Act Oversight: Investigating Patterns ofTerrorist Financing,” February 12, 2002: 4.11
Title III was to create a public-private system for reporting and investigating activity thatcould yield results in the fight against terrorist financing. In doing so, Title IIIexemplified a significant step in oversight responsibilities by the government, in additionto expanded responsibilities for domestic financial institutions. Within Title III, severalparticular sections directly affect the public-private partnership established within thelaw.In complying with the Patriot Act, domestic financial institutions are mostaffected by sections 312, 314, 356, and 363 under Title III of the Patriot Act. Section 312mandates the establishment of a system for private banks to detect and report moneylaundering transactions.21 This means that financial institutions need to create or buildupon their existing reporting apparatus in order to meet Patriot Act requirements.Section 314 empowers the Secretary of the Treasury to establish policies andguidelines for financial institutions and law enforcement to share information aboutterrorist financing.22 In establishing these new procedures, this section seeks to facilitategreater access to information for financial institutions and law enforcement alike in orderto track suspicious activity that could be linked to terrorist financing. For financialinstitutions, that means greater analysis and reports from the government regardingterrorist financing trends. For the government, it means greater access to private sectorinformation in the name of national security.Section 356 requires the Treasury to keep financial institutions up to date withthe regulations, in addition to requirements to share information gathered with respective2122The USA Patriot Act, P.L. 107-56, 107th Congress, October 26, 2001: 26.The USA Patriot Act, P.L. 107-56, 107th Congress, October 26, 2001: 37.12
agencies within the intelligence community.23 With the new law it’s important forbusiness to understand how they are affected year in and year out. It is the Treasury’sresponsibility to take the lead in providing this transparency.To encourage compliance, section 363 of the law increases noncompliance civilpenalties and fines to 1,000,000, up from 10,000 and 250,000 respectively.24Section 366 requires the Treasury to report to Congress on the expansion ofcurrency transaction reporting, and in doing so provide a method for minimizing thesubmission of these reports that provide little utility to law enforcement.25 As eachsection reflects, the Patriot Act requires great participation. In carrying out most of theresponsibilities by the government, the Treasury Department shoulders the burden.The lead government agency tasked with overseeing financial activities withrespect to terrorist financing is the Financial Crimes Enforcement Network (FinCEN),housed within the Treasury Department. In functioning as the main anti-terroristfinancing body, the FinCEN is the lead public agency conveying the Patriot Act messageto the private sector. As Table 1 shows, the dramatic increase in FinCEN’s post-9/11budget reflects the added responsibilities and enhanced capabilities on the TreasuryDepartment to manage this public/private partnership.23The USA Patriot Act, P.L. 107-56, 107th Congress, October 26, 2001: 3.The USA Patriot Act, P.L. 107-56, 107th Congress, October 26, 2001: 3.25The USA Patriot Act, P.L. 107-56, 107th Congress, October 26, 2001: 3.2413
Table 1. FinCEN Budget26 Y00FY03FY06FY09Since the enactment of anti-money laundering programs to address terroristfinancing in 2002, FinCEN’s budget has increased from 51 million in fiscal year 2003 toover 150 million in fiscal year 2014. With respect to manpower, FinCEN’s staff hasprogressively expanded since 2001. This increase in budget and workforce after 9/11suggests a concerted investment in tracking terrorist financing, as evidenced by PresidentBush’s declaration of financial war on terror at FinCEN.27 Since 9/11, breaking upterrorist financing has been a vital interest of FinCEN. The pursuit to combat terrorism isa top priority for FinCEN, as depicted by FinCEN’s strategic report from 2008-2012. Inthe report, two out of the three major initiatives center on anti-terrorist financing. Thefirst strategic goal of FinCEN is to fortify financial institutions against abuse by terrorists,and the second is to focus on deterrence and detection of terrorist financing.28 In effortsto accomplish these goals, FinCEN relies heavily on the private sector with respect to26Financial Crimes Enforcement Network, “Annual Report,” 2000-2014.27Financial Crimes Enforcement Network, “BSA Timeline 1970-Present,” 2007: 114
information sharing. FinCEN is tasked with communication and enforcement of PatriotAct regulations, while businesses report activity through anti-money laundering programs(AML). In tracking terrorist financing, the Treasury Department under the Patriot Acthas dutifully brought the private sector into the fold.Effect on Financial Institutions:The main added responsibility of the private sector under the Patriot Act is inreporting. Provisions in the Patriot Act set strict rules for compliance in reportingsuspicious activity and increased information sharing with law enforcement. Reportingactivity comes in the form of two major reports, suspicious activity reports (SAR), andcurrency transaction reports (CTR). In its purest form, the Patriot Act promotesinformation sharing and coordination with government agencies. In filing both SARs andCTRs the government has amassed a database of information that can be used as aninvestigative tool for law enforcement when pursuing terrorist financing.With respect to reporting information, financial services file SARs. The SAR, atool used to provide a uniform report was created as a part of the Annunzio-Wylie AntiMoney Laundering Act. Under the law, financial institutions are required to flagsuspicious activity.29 At its inception in 1996, the main intent o
Obstruct Terrorism Act of 2001 (Patriot Act), is an effort to combat terrorist financing. Given the unconventional means of a terrorist attack, coupled with the freedom with which operational funds can move from country to country, terrorist financing poses a particularly nuanced threat. Nearly fifteen years have passed since the 9/11 attacks .
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